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Non-Borrowing Spouse Required to Sign Final TIL?

Question: 
On a purchase transaction, is a non-borrowing spouse required to sign the final TIL?
Answer: 

by Dan Persfull:

There is not now nor has there ever been a regulatory requirement for anyone to sign the TIL disclosure on the Federal level.

Having the disclosure signed is a matter of an internal policy, investor requirement or possibly a State law issue.

by Andy Zavoina:

There is a definite difference between documents. Do not confuse the TIL with a rescission form where a nonborrowing spouse may also be a property owner and don’t confuse signing documents with receiving documents or even having a name on a document. It may well be that a nonborrowing spouse receives a rescission and TIL. That person’s name may be on the TIL as a matter of reference or an investor’s rule, but there is no signatory requirement by law or regulation. Similarly, there is no prohibition that it be there, considering the relationship possibilities I’m suggesting in my example. Reg Z neither says it must or must not.

First published on 09/13/2015

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